I am a consumer!

Charlie

Well-Known Member
This is a letter sent to the U.S. FDA with copies to the PM and DFO. It was also sent to every major importer/retailer in the U.S. I was asked to share this information with you, so here it is:

I am a consumer, as such I will no longer be supporting any establishments importing or providing “NON” FDA approved products, until the following can be resolved. In case you are unaware, I am providing the following information. No consumer should support the following practices, period!

SLICE® (emamectin benzoate) has long been opposed by scientists and environmentalists due to lack of thorough scientific research on its effects. Even with Canada’s recent approval, the health effects are still unknown as the Canadian agency did not release many details around the criteria for human safety. Canadian Association of Agri-Retailers (CAAR) has contacted Health Canada requesting approval details and received the disturbing response that research was conducted by the manufacturer, is proprietary, and not available to the public. Scientists have expressed serious reservations about the safety and long-term effectiveness of this drug. It is already known that emamectin benzoate can accumulate in sediments and is a known toxin to fish, birds, mammals and aquatic invertebrates. Its regular use in the farmed salmon industry raises questions about other environmental and health impacts.

Also alarming is Canada’s removal of a required withdrawal period of 68 days between the last use of SLICE® and harvest of the treated fish. Soon, farmed fish will legally go to market regardless of the last time they came into contact with the pesticide. Given that SLICE® has been shown to persist in the tissue of fish and the environment for a period of weeks to months, this should be of particular concern to us American consumers who not only consume over 85% of the Atlantic salmon farmed in BC, but also the fact that the US FDA lists the active ingredient in SLICE® as a banned substance. I have confirmed this, it is “NOT” FDA approved drug; however, it is currently in use at a facility in Maine.
http://www.pewtrusts.org/uploadedFi...s/Protecting_ocean_life/FDA_Letter_Salmon.pdf

CAAR is demanding that Health Canada rescind its approval of this neurotoxin and the Canadian federal government begin a comprehensive and transparent scientific analysis around the environmental impacts of SLICE® use in our ocean waters.

It has come to my attention that drugs and chemicals, such as emamectin benzoate, that have not been approved for use in aquaculture by the FDA are routinely being used by the salmon farming industry worldwide. This drug is used to treat farmed salmon for sea lice infections in Chile, Norway, Canada, Scotland, and the Marine Harvest fish farm in Maine. According to Canadian government information, on average, the unapproved drug emamectin benzoate is being used at least once during the production of every farmed salmon from British Columbia! Any crustaceans under or near the treated area or either killed or severally adversely affected!

I have personally contacted both Marine Harvest Norway (MHN) #8208; parent to Marine Harvest Canada (MHC), which continues to use SLICE® in the production of their Atlantic Salmon. MHC has advised, “the British Columbia industry has averaged about 75,000 tonnes of production so the average usage of emamectin benzoate is about 11#8208;15 kgs (24#8208;33 pounds) annually.” I have this in writing! In fact, Canada law requires treatment for sea lice and SLICE® is their preferred drug. MHC while removing most of their adverse information actually posts some use on its website. They have approximately 18 sites in operation however only 7 sites have information listed and they are NOT providing any additional information to anyone, which is a real concern. Here is their website: http://www.marineharvestcanada.com/farming_farm_locations.php

The FDA has already written and advised three companies and explained, "if the drug is not listed in the approved drugs list they are not allowed to use the drug to treat salmon destined to be distributed in the U.S., not even if they meet withdrawal periods and no tissue residue can be detected." That was indicated in an article from New York Times; however, I have never seen nor been able to verify?

I understand the FDA is responsible for ensuring that all companies exporting salmon to the U.S. adhere to the Approved Drugs in Aquaculture list. I am extremely concerned that the FDA has been made aware of the use of unapproved drugs, but have yet to take any action to correct or stop the importation “illegal” products. I also understand it is each individual company's duty to protect their customers from use of those illegal products. Is that currently happening? The large amount of sea food being imported from foreign countries "Without" FDA approved drugs needs to be terminated, immediately. I strongly urge you to ensure all companies are purchasing/importing "safe" products to the United States and adhere to our laws and the Food and Drug Administration’s Approved Drugs in Aquaculture list.

There is also another very serious threat for us in the Pacific Northwest concerning a disease called Infectious salmon anemia (ISA). ISA is a foreign disease of Atlantic salmon caused by an orthomyxovirus. This virus appears to cause disease only in Atlantic salmon (at this time), both wild and farmed Atlantic (Salmo salar) salmon; however, other wild fish are also susceptible to infection, including sea run brown trout (Salmo trutta), rainbow trout (Oncorhynchus mykiss), and herring. ISA was first discovered in Norway in 1984. Since then, ISA has also been found in New Brunswick, Canada, in 1996; Nova Scotia in 1998; Scotland in 1998; Chile in 1999; Faroe Island in 2000; and Maine in 2001.

I am certainly no expert on influenzaviruses, swine, ISA, or otherwise and have no clinical medicine background, but, I can read! One needs to remember the media are trying to sell their products and also in the case of ISA - they are not really trying to educate anyone. The governments are trying to show that they are on top of things, that they are competent to provide safety and security for the citizens of their country. Sometimes that adds up to people stirring an unstirred pot just to show they can handle a stirred pot. I am not trying to fall into either category; however, I see ISA as a “huge” potential problem for the Pacific Northwest. Not saying it will ever mutate or evolve into anything other than what it already is - but the "potential" is there and we don't really know the current effects it will have on our water vertebrate in particular salmon! We do know it has mutated into a strain currently carried by our Coho… that is proven! Plus, there is another potential problem to consider concerning “us” humans!

This is what I am referring to - “influenza”, which the ISAvirus "is" in its family.
Influenza has been recognized and been around for hundreds of years. In 1892, the German bacteriologist Richard Pfeiffer isolated a bacterium which he considered the causative agent. In 1921, Peter Olitsky and Frederick Gates of the Rockefeller Foundation published their results, which demonstrated that nasal secretions from patients infected with the 1918 influenza virus (influenza A H1N1, vide infra), and passed it through a filter that excluded bacteria, still caused pneumonia in rabbits. Olitsky and Gates had isolated the etiologic agent of this disease but did not recognize that and subsequent studies by others minimized their discovery. Paul Lewis and Richard Shope, also of the Rockefeller Foundation later did similar filtration work and discovered that the bacterium they found, which they called Bacillus influenzae suis, was similar to that which Pfeiffer had isolated.

There are so many examples of this, than I could possibly relate this to which include. “SWINE FLU,” “PIG FLU,” “HOG FLU”, "BIRD FLU", etc. Any of these terms I am sure you are familiar with… as are people all over the world.

Just a little background, On April 29, 2009 Egypt announced that all 300 000 pigs in Egypt would be slaughtered to prevent transmission of this virus to people, even though there is no evidence that the virus had reached Egypt. Israel actually announced it would not call this virus “swine flu,” it would call it “Mexican flu.” Moslem countries have not said anything as yet, as far as I know. In any case, it wasn’t “Mexican” for very long. That bacterium did not cause disease in pigs; however the filtrate did. When the disease they could cause in pigs was found to be more mild than the natural disease, they added their B. influenzae suis to the filtrate and reproduced the severe form of the disease.

To understand a virus – start with the word “influenza,” It was first used in English in 1743 when the disease was recognized in Europe. This word originated with the Italian word influenza, meaning “influence” (Latin: influentia), named so because the disease was considered to be caused by unfavorable astrological conditions. The disease also is known as epidemic catarrh, grippe (from the French), sweating sickness, and Spanish fever (particularly for the 1918 pandemic strain). Hippocrates had clearly defined this disease about 2400 years ago but he lacked laboratory confirmation.

Historically, it has been stated this disease is caused by certain strains of the influenza virus. This is incorrect. There is no such thing as “the influenza virus,” any more than there is “the encephalitis virus” or “the hantavirus” or “the elephant,” virus. Within the virus family Orthomyxoviridae are 5 genera: Influenzavirus A, Influenzavirus B, Influenzavirus C, Thogotovirus, and Isavirus (note ISA has its own classification). Within the former 3 genera are viruses that cause influenza; the thogotoviruses are transmitted to vertebrates by ticks but do not cause influenza, and the single isavirus (which is what we are referring to), infectious salmon anemia virus, is transmitted to fish through water. Influenza A virus (FLUAV), influenza B virus (FLUBV), and infectious salmon anemia virus contain 8 linear, negative sense single-stranded RNAs (viral RNAs, vRNA). Influenza C virus (FLUCV) and Dhori virus (a thogotovirus) contain 7 vRNAs and Thogoto virus contains 6 vRNAs. Superinfections of cells with, for example, 2 different FLUAVs allows for reassortment of vRNAs, which can result in progeny viruses with characteristics of each parent. Here is the problem with a virus, if one parental virus contains genes specifying high pathogenicity and low transmission potential and the other parental virus contains genes specifying low pathogenicity and high transmission, the progeny might have high pathogenicity and high transmission potential. This is not a good thing, but as I understand – any and all virus is subject to mutate or evolve in this potential.

The 8 vRNAs of the influenzavirus A genome produce: PB2 (cap binding transcriptase), PB1 (elongation transcriptase), PA (protease activity [uncertain] transcriptase), HA (hemagglutinin; viral surface projections), NP (nucleoprotein that binds RNA and transports vRNA nucleoprotein), NA (neuraminidase that functions to release virus from the cell; viral surface projections), M1/M2 (matrix proteins), and NS1/NS2 (non-structural proteins; NS1 functions in RNA transport, translation, and splicing; the function of the NS2 is unknown). Obviously this is a complex virus, but the major problem we have dealing with it is that the reassortants that can and do occur can cause trouble for humans and for our livestock and wild friends. Influenzavirus A isolates from birds have provided us with evidence for the presence of 16 hemagglutinins and 9 neuraminidases in various combinations. The subtypes are noted as H1N1, H1N2, etc., based on these characteristic proteins. Pigs, horses, and humans have a much narrower range of subtypes but multiple variants may circulate enzootically among birds and among mammals of certain species, ie, H5N1, H7N7, and H7N3 in birds; H3N8 in dogs; H7N7 and H3N8 in horses, etc. Again, here is the potential problem, Some have been documented to jump species to humans, some have not. In addition to reassortment of genes (genetic shift), small but significant mutations in the nucleotide sequence (genetic drift) can suddenly, or cumulatively over time, bring about alterations in the virus phenotype. The fun never stops… can you relate to what is called the "bird" flu & “swine flu”?

Colloquial expressions such as swine flu, canine flu, equine flu, bird flu, etc. are used, but these terms are neither accurate nor sufficiently descriptive. The virus is the virus; the host is (not so simply) a vehicle.

The proper expression for a particular strain of an influenzavirus, according to the International Committee on Taxonomy of Viruses, should include the name of the virus, the source, the location, the laboratory isolate number, and the year of collection. An isolate from the current outbreak in Mexico might be named influenza A virus/human/TM/123/2009 (H1N1). In other words, it is an influenzavirus A from a human in Tamaulipas State, Mexico, it was the 123rd isolate from the laboratory which isolated it, and was collected in 2009. Btw, in the current outbreak in Mexico, or anywhere else, pigs were not even the first vertebrate hosts shown to be infected.

Therefore, even if a particular strain, might disappear surveillance still must be maintained as an influenzavirus mutates, hence your “new flu” shot each year. A virus might just disappear altogether or it might resurface in a different strain? Determination of the required composition of these influenzavirus is done annually to determine vaccines. Under the current procedures, there is only a 6-month lead time to develop vaccines.

It has been documented this virus was transmitted to Chile from Norway! It has also been documented the disease is most often transmitted by contact with infected live salmon or infected biological materials such as animal wastes or discharges. Infected fish may transmit the disease weeks before they show apparent signs of infection.
http://www.inspection.gc.ca/english/anima/aqua/infect/infectqueste.shtml


Horizontal transmission of the ISA virus in fresh water has been achieved experimentally (Brown et. al. 1998) and occurs rapidly between infected and naive smolts in freshwater. Even under these conditions, asymptomatic smolts may remain infective to naive parr for 18 months after the original challenge (Melville and Griffiths 2000).
http://www.lsc.usgs.gov/fhb/leaflets/FHB85.pdf

The most important thing to remember is, “The ISA virus is an emerging viral pathogen. Based on biochemical, physical, chemical, and structural characterization, ISA virus is very similar to members of the "flu" family (influenza or orthomyxovirus family). Some basic flu virus family principles can be applied when trying to understand the ISA virus. The first general characteristic is that the ISA virus can mutate and evolve. The second is that the virus can change rapidly by recombination of ISA virus genetic elements. There is a significant molecular difference that exists between the "Norwegian,” "Scottish,” and "North American” ISA virus isolations. http://www.aphis.usda.gov/lpa/pubs/tnisa.html

Sixty-five (65%) of all farmed salmon in Chile have ISA. A large amount of Eastern Canada, Norway, Ireland, Scotland, and even in Maine have been exposed to this virus. There are two very important serious issues here:
1. If any piece or part of these virus infected fish, either dead or alive (even while currently safe for human consumption) are imported and ends in our waters this virus will be transmitted to our “wild” fish populations, which could completely eliminate them!
2. This “IS” a VIRUS! And, I relate back to the most important thing to remember about the ISA virus. It is an emerging viral pathogen and the first general characteristics are the ISA virus can mutate and evolve and is subject to jump species, even to humans!

As we have no way of controlling a virus, why are we even allowing this imported? Are we not just asking for another “Bird” or “Swine” flu epidemic?

The second most prevalent parasite in farmed salmon is Kudoa thyrsites, commonly called “soft flesh syndrome.” This is not a virus, but is a disease that affects the quality of the product! This microscopic insect breaks down muscle fiber in fish, turning the flesh to a jelly-like consistency and making it commercially worthless. Deterioration occurs rapidly after salmon are killed and there is no known cure. Kudoa contamination is usually first detected when salmon are slaughtered and processed. Outbreaks have forced many salmon producers to offer discounts or credits for infected fish. According to IntraFish, an industry newspaper, the kudoa parasite affects 20–50 percent of all salmon produced in British Columbia, costing the industry there up to $40 million annually. Atlantic salmon, the predominant commercial stock for farming operations, are more vulnerable to the kudoa parasite than Pacific salmon." http://www.puresalmon.org/pdfs/diseases.pdf

This causes losses to both aquaculture operations, for instance, where salmon are being reared in "sea-pens", and to capture fisheries. Losses are both direct, through the degradation of fish products, and indirectly, through the perception of the consumer that fish from a particular area are of a lower quality. The intensity of K. thyrsites infection is positively correlated with the severity of flesh softening in Atlantic salmon fillets. Softening of flesh always occurred with heavily infected fillets, while lightly infected fillets showed no softening. Prevention and/or control of K. thyrsites infections is problematic especially in open water netpens. Currently there are no available treatments.

Marine Harvest Norway reported: "Quality issues related to soft flesh caused discards and complaints amounting to NOK 26 million in 2008.” This is only one company in British Columbia. http://hugin.info/209/R/1310360/303078.pdf

There are many large farm fish losses posted on the Marine Harvest Canada website 2007-2009.
- Brougham Pt. - lost 142,463 fish July 2009 (Campbell River)
- Bickley Bay - lost 123, 297 fish July 2008, (Campbell River)
- Doctor Island - lost 71,056 fish August 2008 (Broughton)
- Raynore Group - lost 343,226 fish Sep. 2008 (Port Hardy)
- Lime Point - lost 63,875 fish October 25, 2008 (Central Coast)
- Jackson Pass - lost 661,367 fish August 2009 (Central Coast)
- Okisollo Channel lost 500,000 fish Jan – July 2007 (Campbell River)

We know they are having loses from Kudoa thyrsites “soft flesh". However we do not know if these losses are related to other diseases or escapement. Marine Harvest, or Canada is currently required and is “NOT” providing any information, to anyone. One can only assume there is not an outbreak of ISA or any another of the many diseases or threats. But, one can also assume they are exporting and importing these diseased products to the United States. You may assume… I AM NOT BUYING any of their products, until I get a full disclosure of what my family and I are getting ready to consume, as that is a fact!

All products, imported to the United States needs properly inspected, especially food for human consumption. This issue only proves that is not happening. We as consumers and citizens are not receiving the protection we desire or paying for through taxes. Nor are we receiving the quality of products and services from any restaurant and company allowing these diseased and illegal products, not in compliance with our laws.

If informed you or your family were ready to consume something exposed to disease - that was either going to turn the flesh into a jelly-like consistency or exposed or infected with an ISAvirus, would you really eat it? Or allow your children to eat it? This is what we are talking about, I choose - not!

The interesting thing… If I was referring to “China”, I wager I wouldn’t even have to write this… any takers?

Please inform me of your plans to address this serious matter
 
Good post Charlie!

When I first became aware of 'Slice' I was appalled to learn that Health Canada was issuing selective-permits for use in aquaculture while denying its use elsewhere.

It is truly wicked stuff.

Although this info is limited, here's what Oxford University warned about it in a 2005 MSDS document...



Safety data for emamectin benzoate
Environmental Hazard

Glossary of terms on this data sheet.

The information on this web page is provided to help you to work safely, but it is intended to be an overview of hazards, not a replacement for a full Material Safety Data Sheet (MSDS). MSDS forms can be downloaded from the web sites of many chemical suppliers.
General

Synonyms: epimethylamino-4"-deoxyavermectin benzoate (b1a and b1b), MK-244
Use: insecticide
Molecular formula: C49H75NO13
CAS No: 155569-91-8
EC No:

Physical data

Appearance: white powder
Melting point:
Boiling point:
Vapour density:
Vapour pressure:
Density (g cm-3):
Flash point:
Explosion limits:
Autoignition temperature:
Water solubility:


Stability

Stable. Incompatible with strong oxidizing agents.

Toxicology

Eye, skin and respiratory irritant.

Toxicity data
(The meaning of any abbreviations which appear in this section is given here.)
ORL-RAT LD50 1516 mg kg-1
SKN-RBT LD50 > 2000 mg kg-1

Risk phrases
(The meaning of any risk phrases which appear in this section is given here.)
R25 R36 R50 R57 R58.

Transport information

Non-hazardous for air, sea and road freight.

Environmental information

Very toxic to aquatic organisms. Toxic to bees. May cause long-term adverse effects in the environment. This material does not move rapidly through the environment, as it tends to adsorb on soil particles. Half-life in the environment estimated at 8-15 months. Degrades more rapidly when exposed to light.
Rainbow trout LC50 96h 174 ppb
Daphnia magna LC50- 48h 0.99 ppb

Personal protection

Safety glasses, adequate ventilation.

Safety phrases
(The meaning of any safety phrases which appear in this section is given here.)
S26 S36 S45 S60 S61.

[Return to Physical & Theoretical Chemistry Lab. Safety home page.]

This information was last updated on September 6, 2005. We have tried to make it as accurate and useful as possible, but can take no responsibility for its use, misuse, or accuracy. We have not verified this information, and cannot guarantee that it is up-to-date.

Note also that the information on the PTCL Safety web site, where this page was hosted, has been copied onto many other sites, often without permission. If you have any doubts about the veracity of the information that you are viewing, or have any queries, please check the URL that your web browser displays for this page. If the URL begins "http://msds.chem.ox.ac.uk/" the page is maintained by the Safety Officer in Physical Chemistry at Oxford University. If not, this page is a copy made by some other person and we have no responsibility for it.


My question is: If it has a half-life in the environment of some 8 to 15 months while degrading more rapidly with increased light, how long does it remain stable residing in the (dark places) tissues of fish?

"M-m-m-m... yummy Mummy! Pass me another serving of that wonderful farmed salmon!"

"Some could care less if there's any fish left for our kids!"
 
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